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ICD-10 Delay - Advice for Hospices


ICD-10 DelayICD-10 Delay - Advice for Hospices

Everyone was counting down until October, 2014.  The US healthcare community had been steadily preparing - although perhaps not without some grumbling and complaining along the way –for the implementation of ICD-10.  ICD-10 ­would happen on time on October 1 we were told – there would be no more delays.

Then “April Fools” happened.

On April 1, 2014 President Obama signed into law the “Protecting Access to Medicare Act of 2014.” The main component of the law was a one year “patch” in the SGR (Sustainable Growth Rate, which impacts how much physicians are reimbursed by the Medicare program).  But tucked deep inside the bill was a single sentence (Section 212), which directed the US Department of Health and Human Services to delay until at least October 1, 2015 the implementation of planned transition to ICD-10.

So it seems that hospice providers have at least a year’s reprieve for the implementation deadline (at least for now). 

But the delay in implementation doesn’t mean that hospice providers should slow down or discontinue their preparation efforts.  So what does the delay mean for hospice providers and how should they move forward with their ICD-10 planning?  Here are some suggestions.

What is the new deadline?

Although the law stipulates that DHHS cannot implement ICD-10 before October 1, 2015, it doesn’t stipulate exactly when the conversion will take place.  That decision will be left up to DHHS and thus far no new specific deadline has been set.  Hospices need to remain vigilant to make sure they don’t miss the announcement of the new deadline.  But until the new deadline is announced, hospices should assume and prepare as if October 1, 2015 is the new ICD-10 conversion date.

Stretch, but don’t stop

After the announced delay, hospices are encouraged to pause a moment, take a deep breath… and then keep right on working.  Organizations should work to maintain their forward momentum, even if it means adjusting your internal calendar and stretching out key milestone dates.  Once a new deadline is set, it may be helpful to work backwards from that point, considering the current state of your projects and preparedness. The advice here is not to stop and try to restart the project again in six months but to keep on plowing forward.  Organizations that do so are likely to be in much better shape when the new deadline rolls around.

Use the extra time to train and to test

It’s well known that the ICD-10 code set brings with it a truckload of new codes and new coding procedures.  Hospice providers should use the extra time caused by the delay to thoroughly teach and train their staff on the new coding system.  For example, clinicians will need to consider how to crosswalk their most common ICD-9 hospice diagnosis codes into IDC-10. Hospices may decide to use the extra time to bring on new staff (such as a certified coder) or evaluate the possibility of outsourcing their coding.

Hospices should also renew their testing efforts, ensuring their systems can support ICD-10.  This includes continuing conversations with software vendors, clearinghouses, payers and other partners to ensure on-time compliance with the new deadline.  The extra delay may even provide the opportunity for some providers to dual-code – another suggestion that may limit interruptions in reimbursements when the ICD-10 switch is flipped.

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Hospice Item Set: What You Should Know


Hospice Item SetBeginning July 1, 2014, hospices will be required to begin using the Hospice Item Set (HIS) for all patients. This will have a payment impact in FY 2016. Hospices will need to begin to prepare now for this new reporting.

What is the Hospice Item Set (HIS)?
Implemented as part of the FY 2014 Hospice Wage Index Final Rule, the HIS is a set of data elements that are used to calculate the following quality measures:

  • NQF #1641: Treatment Practices
  • Modified NQF: #1637: Beliefs/Values Addressed
  • NQF #1634 & #1637: Pain Screening and Pain Assessment
  • NQF #1638 & #1639: Dyspnea Screening and Dyspnea Treament
  • NQF #1617: Patients Treated with an Opioid who are Given a Bowel Regimen

The HIS is not a patient assessment tool, but rather a standardized tool for abstracting data from the clinical record. It is not administered directly to the patient or family.

Who must submit HIS?
All Medicare-certified hospices must submit. Data should be collected and submitted on all admissions for patients age 18 years and older.

What data is submitted?
Hospices will be required to submit two HIS records for each patient admitted: a HIS-Admission record and HIS-Discharge record. These records are to be submitted electronically to CMS on an ongoing basis.

How should hospices implement the HIS?
One method of implementation involves matching items currently in your clinical record or patient assessment forms to items in the HIS. Most hospice software vendors, including HEALTHCAREfirst will provide the ability to capture the data items necessary for extraction and submission.

For additional information about the Hospice Item Set, hospices should visit CMS' Hospice Quality Reporting page.

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HEALTHCAREfirst and BKD to Host Free Webinar for Hospice Agencies


New Hospice Billing Changes

HEALTHCAREfirst  is partnering with BKD, LLC to host a free webinar detailing the latest information regarding CMS Change Request (CR) 8358.

Presented by Deanna Loftus, Director of Regulatory Compliance for HEALTHCAREfirst and Aaron Little, Managing Director of BKD, LLP, the webinar will review the latest information regarding new data reporting requirements, address data reporting related questions and offer practical tips for complying with the new requirements including:

  • Review of new hospice billing requirements based on CR 8358, including the most recently issued information released in January 2014.
  • Review of key elements of new data reporting requirements related to electronic claim formatting.
  • Discussion of practical tips for complying with new requirements.

Hospice Administrators, Directors, Managers and billing staff  won’t want to miss this!

The webinar will be held on April 8, 2014 at 10:30 am Central time. It is free of charge, however you must register in advance to attend.  Click here to register.

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Hospice Additional Data Reporting: What You Should Know


Hospice Data Reporting

By now, most of the hospice community is well versed on the additional data reporting requirement that will be mandatory for dates of hospice service on or after April 1, 2014.  In this brief article we hope to offer some tips and resources to assist you and your hospice team as you prepare for compliance with this rule.

Additional Data Reporting – What’s Required?

On July 26, 2013, CMS issued Change Request 8358 (CR 8358) detailing the additional information hospices will be required to report when submitting their claims for payment.  The requirement is designed to provide additional data to support anticipated hospice payment reform. 

Specifically, CR 8358 requires hospices to provide additional information on their hospice claims regarding:

  • the location of care when billing General Inpatient Care (GIP) level of care;
  • the NPI of any SNF, hospital or hospice IPU when the location of care is not the same location as the billing hospice's location;
  • the use of a -PM modifier when visits occur after death and on the same date of death;
  • the use of injectable and non-injectable prescription drugs; and
  • the use of infusion pumps.

Additional Data Reporting – Moving Toward Compliance

  1. Identify current systems and workflow regarding the care of hospice patients receiving GIP level of care, post mortem visits and the utilization of hospice provided prescription medications and infusion pumps. Remember that your processes may include involvement from both clinical and non-clinical (or support) staff, so be sure your review is complete.
  2. Once you’ve identified your current workflow as it relates to the additional reporting requirements of CR 8358, assess your readiness for compliance. Where does your program need to improve its systems, processes and work flow? What gaps have you uncovered?

    You might want to consider:
    • Since you will be required to report the NPI of any nursing facility, hospital and non-owned hospice inpatient facilities, do you have that information readily available? Should you consider amending your contracts with these facilities to insure the collection and verification of this data?
    • Are you currently capturing visit time in these facilities? Is it accurate? Does the visit time already flow onto your hospice claims?
    • Do you need to talk with your local pharmacy vendor(s) or your pharmacy benefit manager (PBM) to make sure you have information regarding the National Drug Code (NDC) for hospice-provided prescription medications? If your program pays for medications on a per diem basis, how will you collect the NDC and charges for the individual medications? Similarly, if your hospice uses a “comfort kit” do you have the NDCs and charges for the individual medications in the kit available?
    • As a part of your readiness assessment, remember to consider the knowledge and education of your staff. Does your staff understand the new compliance requirements? How will you get them up to speed?
  3. Develop a compliance strategy and action plan. Once you’ve examined your current processes and workflow and assessed for gaps in compliance, it’s time to draw up your compliance plan and put it into action. Most likely you will discover the need to at least partially modify some of your current systems and work flows.  As you implement these changes, remember to fully educate your staff on the changes required and why compliance is important.  
  4. Prepare for contingencies, including the need to reevaluate your changed processes and retrain staff. 

You may find it helpful to incorporate your preparations for compliance with CR 8358 into your overall existing QAPI program.

HEALTHCAREfirst is working now to address the changes required by CR 8358.  Enhancements to our firstHOSPICE product are already in production and are slated for release in the coming weeks to assist our hospice clients with these changes and ensure their ongoing regulatory compliance. 

For more information regarding HEALTHCAREfirst and our firstHOSPICE Web-based hospice agency management software solution, contact us at 800.841.6095 or click here to request a free demonstration.


Hospice Regulation Changes: A 2014 Snapshot


Hospice-Regulatory-Changes-2014With a plethora of new rules and regulations on the horizon, 2014 promises to be a very busy year for hospice providers, particularly for hospice staff responsible for regulatory compliance.  Here’s a quick snapshot of some of the major regulatory changes happening in 2014.

Additional Data Reporting on Hospice Claims – CMS Change Request 8358
Dates to Remember: Voluntary reporting begins January 1; mandatory reporting begins April 1

On July 26, 2013, CMS issued Change Request 8358 (CR 8358) detailing the additional information hospices will be required to report when submitting their claims for payment as authorized by Section 3132(a) of the Affordable Care Act.  Specifically, CR 8358 requires hospices to provide additional information regarding:

    • the location of care when billing for General Inpatient Care (GIP) level of care;
    • the NPI of any SNF, hospital or hospice IPU when the location of care is not the same location as the billing hospice’s location;
    • the use of a -PM modifier when visits occur after death and on the same date of death;
    • the use of injectable and non-injectable prescription drugs; and
    • the use of infusion pumps.

Conversion to the ANSI 5010 Claim Format / Revised CMS-1500 Form
Date to remember: April 1, 2014

HIPPA requires that the Department of Health and Human Services (HHS) adopt new standards for healthcare providers and other covered entities to use when conducting certain health care transactions electronically, including the processing of electronic claims.  For hospice providers who bill electronically, this change should go mostly unnoticed. 

Sunset of HIQA and Complete Conversion to HETS
Date to remember: April 7, 2014

On April 7, 2014, CMS will completely sunset the use of Health Insurance Query Access (HIQA, part of the DDE system) and move to HIPPA Eligibility Transaction System (HETS) for the release of information related to beneficiary eligibility for services. CMS has indicated the HETS system will be able to provide information on previous hospice admissions similar to the current HIQA system before the sunset date.

Hospice Item Set (HIS)
Date to remember: July 1, 2014

As required by CMS 42 CFR Part 418 Hospice Wage Index and Payment Update published on August 7, 2013, hospices will be required to collect and report data related to seven quality measures. Hospices are required to report two HIS records for each patient – a HIS-Admission record upon admission and a HIS-Discharge upon discharge. 

ICD-10 Conversion)
Date to remember: October 1, 2014

After several delays, all U.S. healthcare providers will be converting from ICD-9 to ICD-10 on October 1st. CMS has already announced a National Testing Week for March 3-7.

For information regarding HEALTHCAREfirst and our firstHOSPICE Web-based hospice agency management solution, contact us today or visit us online at

Mythbusting: Dispelling Misconceptions about Hospice & Palliative Care


World-Hospice-Day-LogoToday is World Hospice & Palliative Care Day.

It is a unified day of action to celebrate and support hospice around the world.  The theme for this year’s celebration is, “Achieving Universal Coverage of Palliative Care: Dispelling the Myths.”

There are many misconceptions in the public about what hospice and palliative care are and what they aren’t.  Over this past week, we have been sharing on Facebook some of these myths, courtesy of the Worldwide Palliative Care Alliance.  We encourage you to share these with others in your area, in order to help raise awareness and understanding of what hospice and palliative care truly mean.

MYTH: Having hospice and palliative care means you will die soon.

FACT: Hospice and palliative care is not just for the end of life. It is a holistic approach that includes caregiver support, spiritual care, bereavement and much more.

The truth is…Hospice and palliative care is about having the best quality of life for however long life remains. Palliative care patients have serious illnesses that eventually bring about the end-of-life but up until then it is important to be free from pain, symptoms, and suffering. Recent studies show that many patients who receive palliative care may live longer than those receiving standard care based on a more curative model.

MYTH: Hospice and palliative care is just for people with cancer.

FACT: All those who are diagnosed with a chronic life-limiting illness can benefit from hospice and palliative care.

The truth is…Many people still think that hospice and palliative care are just for cancer patients. In the early days of hospice most patients had cancer but as hospice and palliative care have grown, more patients with non-cancer life threatening conditions are being cared for. These conditions include heart, lung, liver, kidney, brain, and motor neuron diseases as well as very frail elders. International research shows that about 70% of all people who die would benefit from access to palliative care services.

MYTH: Palliative care manages pain through the use of addictive narcotics.

FACT: Palliative care is holistic care that provides psychosocial and spiritual care along with pain and symptom management.

The truth is… The founder of the modern hospice movement, Dame Cicely Saunders, came up with the concept of “total pain” to describe how patients with life limiting illnesses experience suffering in many dimensions. These include physical, social, psychological, and spiritual or existential suffering. Pain relievers like morphine are essential to good palliative care to relieve pain and other symptoms and can be safely used, but other measures are also needed to address pain including counseling and social support.

MYTH: I can only get palliative care in a hospital.

FACT: Palliative care services are offered in many places, including hospitals, hospices and in your own home.

The truth is… Hospices and palliative care programs provide care wherever the person and family reside. Usually that is the place you call ‘home,’ whether it’s a private home, an assisted living facility or nursing home, or even a shelter. In fact the majority of palliative care is home-based care. Palliative care can also be provided for short periods in the hospital or in special hospice units or freestanding inpatient facilities.

MYTH: Hospices are generally just for old people.

FACT: Hospice and palliative care is for people of all ages.

The truth is… People don’t like to think that children die, however a big part of palliative care is care for children. People of all ages can develop a life limiting illness and palliative care programs need to be prepared to care for patients of any age. In some countries there are special hospices and palliative care services devoted to the care of children. 

MYTH: Everyone has access to hospice and palliative care.

FACT: Though every person has the right to hospice and palliative care, there are many around the world who do not have access to hospice and palliative care. In fact only about 10% of the need for palliative care is currently being met worldwide.

The truth is… Access to palliative care is a human right. No healthcare system in a country is complete without including palliative care as an available service. However palliative care is mostly limited to countries in Western Europe, North America, and Australia. Efforts are underway to expand palliative care to low and middle income countries so that every country can have palliative care. A recent study identified 43% of countries with no palliative care delivery.

What other myths or misconceptions about hospice and palliative care have you heard? How has your agency worked to dispel them? We would love to hear from you!

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The Value of Social Media for Hospice Agencies


Social Media in HospiceThe use of social media such as Facebook and Twitter can be a powerful tool for hospices looking to share ideas, news and build relationships online. Using social media effectively can also increase your online presence, helping your agency show up more frequently in search engines like Google or Yahoo.

Here are some tips on how you can use social media to engage caregivers, consumers and the community:

  1. Begin by creating accounts with the most popular social media including Facebook and Twitter. Don't be afraid to explore other types of social media including Instagram, Pinterest and LinkedIn too.
  2. Do you have a website?  If so, develop a blog to go along with it.  Blogs are designed to provide news, commentary and updates on the latest happenings in your organization and hospice industry.  You will find that many people will subscribe to your blog and read it regularly.
  3. "Friend" or "follow" other local businesses from your community.  "Like", "share", "re-tweet" and comment on their posts.  This will help spread your brand to their friends and followers that may not be connected to your business just yet.
  4. Use your account to promote education about hospice care, events your agency may be hosting or attending and even spotlight your staff or agency achievements.
  5. Encourage your staff members to connect to the agency account by “friending”, “following”, “sharing”, “liking” and “tagging”.  Just be sure to create an internal social media policy and educate your staff on acceptable use when posting on or about the agency account.

Once you get started and have your accounts set up, it only takes a few minutes a day to update your social media message and get the word out about your agency.   As the viral generation grows, more and more people will be looking to the Internet and social media to find care options for their loved ones.  Don’t be left behind!

Want to see examples of social media sites?  HEALTHCAREfirst is on a number of sites including Facebook, Twitter, LinkedIn and an online blog.

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National Healthcare Decisions Day


The Importance of Advance Care Planning

National Healthcare Decisions DayDid you know that in a past study conducted by the U.S. Agency for Healthcare Research and Quality, less than 50% of terminally ill patients had and advance directive in their medical records?

Today, April 16th, has been designated as National Healthcare Decisions Day.  On this day, we encourage home health and hospice caregivers to educate your patients on the importance of expressing their wishes regarding healthcare.  All adults can benefit from discussing and identifying the healthcare choices they want made should they be unable to do so on their own.  Most can utilize an advanced directive so that loved ones as well as medical professionals are aware of their desires.

There are two types of Advance Directives: a living will and medical power of attorney.

Living Will

A living will is a legal document that allows someone to control his/her wishes for medical treatment at the end of life. It covers health care decisions when they are terminally ill or permanently unconscious and unable to make decisions on their own.  State laws vary on the exact terms of a living will, but they are generally designed to allow doctors to stop the process of prolonging life. 

Medical Power of Attorney

A medical power of attorney legally allows a person to name someone else who is designated to make decisions about their medical care should they become temporarily or permanently unable to express those wishes on their own. Many people may have both a living will and a medical power of attorney directive.  The medical power of attorney is able to make decisions that were not addressed in the living will.

Talking about advance directives is an important part of the caregiving process, particularly in hospice care. Educating your patients about their desires can help to empower them about their health care choices.   The internet has a number of fantastic resources available to families and caregivers who are interested in learning more about advance directives as well as communicating end-of-life wishes including:

The Conversation Project
Dedicated to aiding families in discussing their wishes for end-of-life care and treatment.

Caring Connections from NHPCO
From the  National Hospice and Palliative Care Organization, provides free advance directives and instructions for each state  

End-of-life planning guidance and advice for families

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Hospice Claims RTP’ing with Reason Code 32061


This just in from CGS...

On April 2, 2013, CGS notified providers through a listserv message that a system problem had been identified which impacted hospice claims (types of bill 81X and 82X). CGS has also determined this is affecting type of bill 34X. These claims were being returned to the provider (RTPd) inappropriately with reason code 32061. The Centers for Medicare & Medicaid Services (CMS) has informed CGS that this edit will be turned off, and contractors can release these claims to continue processing. Providers with claims in status/location T B9997 with reason code 32061 do not need to take any action. CGS is in the process of releasing these claims, and anticipates all claims to be released within the week.

Hospice Reason Codes Returned to ProvidersHospice Claim Reason Codes Returned to Providers

Two of the Medicare Administrative Contractors (MACs) have reported a system issue impacting hospice claims (types of bill 81X and 82X) that are being returned to the provider (RTPd) inappropriately with reason code 32061.  This reason code indicates a split claim is required on all non-PPS bills when the TO date on the claim overlaps the fiscal year end of the provider.

The MAC’s that have currently reported this are CGS and Palmetto GBA, both of which have posted notices to their claims processing logs on their websites. They hope to have the issue resolved soon. Currently NHIC and NGS have not posted any information on their websites regarding whether or not this is impacting their providers.  

Palmetto GBA: Click here.

CGS: Click here.

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Louisiana Scraps Plans to Cut Medicaid Hospice Program


La Hospice Reversal PlanYesterday, Louisiana’s Health and Hospitals Secretary Bruce Greenstein announced the reversal of plans to cut the Medicaid hospice program.  The announcement was made as hospice program supporters gathered on the state capitol steps to protest the cut.

The cut would have made Louisiana one of only two states that don’t pay for hospice care through its Medicare program. There was strong resistance from state senators and hospice advocates alike.  They argued that cutting hospice would not save the state money, as hospice care costs approximately ¼ of the same treatment received in hospitals.

The state will use federal grant funding to keep the hospice program running.

We applaud the state of Louisiana on the decision to not make cuts to hospice care for Medicaid patients, recognizing the value of hospice care for everyone.

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